Last updated: [24 March 2021]
1.2. Users of the Services (“you” or “your“), particularly job applicants (“Candidates”) on the Platform, are to read this Policy carefully and to refer to it as and when required. By accessing the Website and/or using the Platform and/or the Services, you are deemed to have accepted our practices as described in this Policy and undertaken to comply with the same.
1.3. We recognise your privacy and have adopted this Policy which is compliant with the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”) and the European Union General Data Protection Regulation (“GDPR”) to reflect our commitment to respecting and protecting your privacy and personal data.
1.4. This Policy outlines the personal data that we collect, how it may be used, how it is stored and retained, whom it may be transmitted to, as well as our and your responsibilities in relation to such collections, usages and disclosures.
1.5. The PDPA recognises the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organisations to collect, use or disclose personal data for legitimate and reasonable purposes.
2. Collection of Personal Data
2.1. We collect personal data and confidential information (collectively, “Personal Data”) from and about our candidates upon their engagement of our recruitment services. Personal data means data, whether true or not, about an individual who can be identified: (i) from that data; or (ii) from that data and other information to which we have or are likely to have access. This Personal Data will include, but may not be limited to the following information: [Aurora to review and update the following list]
(a) Your full name, including any aliases;
(b) Your NRIC/ Passport Number;
(c) Your date of birth;
(d) Your gender;
(e) Your residential address;
(f) Your nationality;
(g) E-mail address(es) and other contact information that you may provide to us;
(h) Your CV/resume or related information documenting your working experience or academic qualifications/certifications;
(i) Your photographs/ images;
(j) Your current and/or desired salary, remuneration package, and/or employment benefits;
(k) A record of any correspondence between you and us through the Platform;
(l) Your assessment results and background check results;
(m) Information about you provided to us by your referees or our Clients;
(n) Information that we may require from you when you report a problem with the Platform or the registration process;
(o) With regard to each of your visit to our Website we may collect, in accordance with applicable laws and, where required, with your consent, information relating to the devices you use and the networks that they are connected to when using our services. This may include the following information: your IP address, log-in information, smartphone device brand and type, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, information about your visit including the URL clickstream to, through and from our Website, products you viewed or searched for, download errors, length of visits to certain pages, and page interaction. We may collect this information through the use of various technologies including cookies; and
(p) Any other information that you provide to us through the Website.
2.2. We will collect only the information listed in paragraph 2.1 above that is reasonable for us to provide you with our services.
2.3. We make a reasonable effort to ensure that the personal data collected is accurate and complete. We will not be responsible for relying on inaccurate or incomplete data arising from your failure to notify us of any changes or inaccuracies in your personal data that was initially provided.
2.4. In the event that your account on or access to the Platform is suspended or blocked, we will keep your data for a period of between 2 and 10 years in order to prevent you from circumventing the rules applying to our Platform, after which we shall cease to retain your personal data.
2.5. We will cease to retain your personal data when the purpose for which the personal data was collected is no longer being served by the retention of the same, and it is no longer necessary for legal or business purposes.
2.6. We only collect such information when you choose to supply the same to us. You do not have to supply any personal information to us but you may not be able to take advantage of all our Services without doing so.
3. Consent to collection, Use and Disclosure of your Personal Data
3.1. The provision of your Personal Data to us will be deemed as consent to our collection, use and disclosure of your Personal Data for the purposes set out in this Policy.
3.2. The provision of the personal data of third parties, such as your referees and your next-of-kin, will be deemed as you having obtained the consent of such third parties to our collection, use and disclosure of their Personal Data for the purposes set out in this Policy.
4. Use of information
4.1. By using the Platform and/or our Services, you expressly authorise and consent to us gathering, reviewing, retaining and where reasonably required, transmitting your Personal Data to our intermediary companies and entities for the proper and reasonable purpose of them storing and using the data responsibly and in accordance with the PDPA. When you provide Personal Data through our Website and/or Platform, the information may be sent to servers located outside of Singapore.
4.2. We will also take appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the PDPA.
4.3. We may use this information for the following purposes: [Aurora to confirm the following list]
(a) To verify your identity;
(b) To match you with suitable employment opportunities;
(c) To assist recruiting employers who have engaged our services (our “Clients”) in assessing your suitability for employment opportunities;
(d) To assist in your career planning and professional development;
(e) To obtain statistics about users and Candidates so that we may improve and further develop our business processes, Website, Platform, and Services;
(f) To respond to requests and queries (if any) from our Clients concerning you as a Candidate;
(g) Ensure that the content on our Website and Platform is presented in the most effective manner for you and your personal computers, smartphones and other devices, customise the Website and Platform to your preferences, understand your activities interests, optimise our Website and Platform’s display of information, and manage our business;
(h) Carry out and administer any obligations arising from any agreements entered into between you and us;
(i) Allow you to participate in features of the Website and Platform and receive our Services to facilitate recruitment, explore careers, seek out and be matched with career opportunities;
(j) Communicate with you by email or other chosen means to send relevant notifications about our events and services that may be of interest to you;
(k) Contact you and notify you about changes to the Website, Platform or our Services (except where you have expressly requested for us not to do so);
(l) Analyse how users are making use of the Website and Platform for our internal marketing and research purposes;
(m) Ensure that you comply with our terms and conditions and the applicable law;
(n) Send to you important notifications that you will require in order to use the Website, Platform, and our Services;
(o) To otherwise reasonably provide our Services and/or other related services to Candidates and our Clients; and
(p) To promote our other services.
5. With whom we share your information
5.1. We do not share your personal information with others except as indicated in this Policy or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:
(a) Our employees, agents, and Clients located in Singapore, United Kingdom and Malaysia (and any other countries where we may provide our services in the future) regarding possible work placements or to assist us in providing our services to you;
(b) Your referees, institutions and professional bodies;
(c) A professional association or registration body that has a legitimate interest in the disclosure of your personal and sensitive data;
(d) Our insurers;
(e) Any government agency that has the right to obtain the data;
(f) Third party providers of background check services;
(g) Any person with a lawful entitlement to obtain the data; and
(h) Service providers: We may share information, including personal information, with third parties that perform certain services on our behalf. These services may include, without limitation, server hosting, marketing and supporting our notification service functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to disclose or use such information for any other purposes.
5.2. We may allow third party service providers, advertising companies, advertisement networks, merchandising companies and other third parties to display advertisements and brands on our Website and Platform. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements.
5.3. We do not provide any non-anonymised personal information to third parties. We will adhere strictly to the provisions in the PDPA in relation to any disclosure and dissemination of information to any third parties.
5.4. We may disclose your information, including personal information, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agencies, to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law.
5.5. We will not transfer any of your personal data to a country or territory outside Singapore except to organisations that provide a standard of protection to personal data that is comparable to the protection under the PDPA.
6. Refusal to give us the information we are seeking
6.1. You can refuse to provide us with your Personal Data. However if you do not give us this information, we may not be able to provide our services to you. For example if you are a Candidate, we may be limited in our ability to identify suitable job opportunities for you.
7. Direct Marketing
7.1. We may sometimes use personal data for marketing purposes but only in the following ways:
(a) We will contact you while you are registered with us with updates in relation to employment opportunities, career tips, industry/market insights and promotions from time to time;
(b) We will send to subscribers of our Website news and job alerts to which they have subscribed; and
(c) We will contact Clients with whom we have a relationship with industry/market information and promotions from time to time.
7.2. When sending direct marketing material we will give you the option as to whether or not you wish to receive further marketing communications. We usually use email, phone, WhatsApp, and/or SMS. If you wish to change your preferences for contacts, please contact us at email@example.com.
8. Third Party Sites or external sites
8.1. Our Website or communications may contain links to or from other websites. External sites that are linked to or from our Website are not under our control and you are advised to review their privacy statement. Users should note there are inherent risks associated with the transmission of information via the Internet and you should therefore make your own assessment of the potential risk to the security of your information.
8.2. For example, if you click on an advertisement (news and promotions) on our Website or Platform, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. You are advised to consult the privacy statements of all third-party websites that you visit.
9. How we protect personal data
9.1. We take all reasonable steps to protect your personal data from misuse, loss, unauthorised access, modification and disclosure.
9.2. We have a number of safety measures in place to protect your information. For example, your personal data is stored in a customer relationship management system in Singapore and which provides management controls for identity access and provisioning. Access to the database is only granted to those who require such access. All staff are bound by a confidentiality agreement regarding company and customer information.
9.3. As our information technology storage facilities and servers may be located in other jurisdictions, your personal data may be transferred to, stored, used and processed in a jurisdiction other than Singapore. You understand and consent to the transfer of your personal data out of Singapore as described herein.
9.4. Where we transfer your personal data to a country outside of Singapore, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA and GDPR.
9.5. If you wish to delete your personal data in our possession, please email us at firstname.lastname@example.org. Your personal data in our possession will be deleted within 24 hours.
10. Children's privacy
10.1. Although our Website and Platform are for a general audience, we restrict the use of our Platform to individuals aged 18 and above. We do not knowingly collect, maintain, or use personal information of children under the age of 18. It is your sole responsibility to provide your correct birth date.
11. No Third-party Rights
11.1. This Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Platform.
12.1. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will review our policies, procedures and processes from time to time.
12.2. We reserve the right to amend the terms set forth under this Policy at our absolute discretion.
12.3. We will post details of any changes to this Policy on the Website and Platform to help ensure that you are always aware of the information that we collect, how we use it, and in what circumstances, if any, that we share it with other parties.
12.4. You are encouraged to visit the Website and Platform from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
12.5. If you do not agree to the updated policy, you must stop accessing or using the Website, the Platform and our Services.
13. Specific provisions related to the European Union GDPR
13.1. We acknowledge that the GDPR will apply if we process or hold any personal data of individuals residing in the EU or if we offer goods or services to individuals in the EU (“EU Individuals”).
13.2. We understand that we may lawfully process personal data if consent is provided by the EU Individual for the processing for specific purposes, if it is necessary for the performance of a contract of if it is necessary for our compliance with a legal obligation.
13.3. We understand that personal data must be processed lawfully, fairly and transparently, be collected and applied only for specified, explicit and legitimate purposes, must be limited to only what is required, must be accurate, not be kept in personally identifiable form for longer than is necessary and must be secured and protected pursuant to the GDPR.
13.4. We acknowledge and agree that the GDPR affords EU Individuals with rights such as:
(a) The right to access and obtain a copy of the EU Individuals’ personal data, including the purposes of processing and who the personal data has been disclosed to;
(b) The right to rectify inaccurate personal data concerning the EU Individual;
(c) The right to erasure of personal data concerning the EU Individual in certain circumstances;
(d) The right to restriction of processing of personal data in certain circumstances, such as where the accuracy of the personal data is contested, or the processing is unlawful;
(e) The right to data portability by receiving personal data concerning the EU Individual or data which has been provided to us, in a structured, commonly used and machine-readable format, and the right to transmit that data to another organisation;
(f) The right to object to the processing of personal data in certain circumstances, including for the purposes of direct marketing; and
(g) The right not to be subject to automated decision-making (including profiling) where this has a legal effect on the EU Individual or significantly affects him.
13.5. We agree that we will act on a request from an EU Individual without undue delay (within one month). We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments and the need to apply careful consideration in the adoption and engagement of our data processors.
14. Consent withdrawal
14.1. You are entitled to withdraw your consent for the collection, use and disclosure of your personal data by giving us reasonable notice by sending a written request to our Data Protection Officer at the contact details provided by paragraph 15.
14.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the implications of such withdrawal.
14.3. We may also ask you to verify your identity and for more information about your request.
14.4. In general (and provided you have given us sufficient information for us to process your request), we shall seek to respond/process your request within ten (10) business days of receiving it.
14.5. Please note that withdrawing your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is required/permitted under applicable laws.
15. Contact & Data Protection Officer
15.1. If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or request relating to your personal data, including but not limited to, the following:
(a) Any request to provide you with your personal data that is in our possession or control;
(b) Any request to withdraw your consent for the collection, use and/or disclosure of your personal data;
(c) Any enquiry on the ways in which your personal data has been or may have been used or disclosed by us within one year prior to the date of the enquiry; and
(d) Any request to correct an error or omission in your personal data,
they should use one of the following means:
(a) Email to our Data Protection Officer at email@example.com; or
(b) Post to: Aurora Talent Pte. Ltd. 20 Collyer Quay, #09-01, Singapore 049319